When an automobile reaches the end of its useful life, it faces the same relative fate all of the materials that we use face; they are disposed and, where applicable, recycled. Unlike simple household trash, disposal of vehicles poses a bit more of a challenge.
The countless parts and components that are in our automobiles can pose an environmental threat if not properly managed. The various fluids, switches (that may contain mercury), paints and coatings (that may contain cadmium, nickel, and chromium), lead-acid batteries, brake pads (that may have asbestos), tires, and more require special handling and waste-disposal considerations.
End-of-Life Vehicles
The challenges of addressing automobiles that are at the end of their useful life isn’t “news” or new. What is new is how the Ontario government is regulating automotive recycling facilities that manage end-of-life vehicles (ELV). These regulations came into “force” on March 31, 2016, but the grace period for registration is about to expire.
According to the Ministry of Environment and Climate Change (MOECC), “All eligible ELV waste-disposal sites will be required to register their activities on the EASR by September 30 of 2016. As of September 30, 2017, ELVs will be designated as a waste under Regulation 347 and, therefore, ELVs and any wastes removed from ELVs must be managed in accordance with the requirements in the regulation” (emphasis added).
Specifically, as it relates to Regulation 347 (referenced above), it was amended to require ELVs to be “depolluted” prior to crushing, shearing, or shredding. For example, depollution of all fluids must take place on an impermeable pad with spill containment. In addition to the removal of all fluids, refrigerants must be removed, along with anti-lock brake sensors, tires, lead-battery cable connectors, tire weights, and brake pads containing asbestos.
Environmental Activity and Sector Registry
According to the MOECC, designating ELVs as a waste would require that ELV sites obtain an Environmental Compliance Approval or ECA (if they do not meet the exemption). However, the MOECC has stated that, “… to alleviate the time and financial burden that could be associated with requiring an ECA, the ministry has filed an EASR regulation for ELV waste disposal sites.”
For those automotive recyclers to whom this applies, you must register your ELV waste-disposal site on EASR if
- You store ELVs for more than 180 days or engage in activities other than the collection, handling, transportation, storage, and/or transfer of ELVs or
- You have more than 10 ELVs on site, receive more than two ELVs per year, or engage in activities other than the removal of parts from ELVs for reuse and the collection, handling, transportation, storage, and transfer of ELVs.
There are several conditions that would “bump” you out of the EASR and would necessitate that you obtain an ECA (for example, if your site has been identified as a “significant drinking water threat in a source protection plan,” or if you accept PCB wastes, radioactive waste, or biomedical waste to name a couple).
As is always the case, there are many details to this new regulation. Should this potentially impact you or your client, you can read more at Ontario Regulation 85/16, “End-of-Life Vehicles.”
If you have other questions relating to environmental compliance, assessment, remediation, etc., please feel free to contact me (cpare@dragun.com) at 519-979-7300, ext. 114.